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TGDC weighs barcode, QR code limits in VVSG 2.1 as local officials warn of trust and cost impacts

Technical Guidelines Development Committee, Election Assistance Commission · July 31, 2025
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Summary

Committee members debated proposed VVSG 2.1 language limiting barcode/QR code use to cases tied to accessibility; local election officials warned the rule could require costly changes or expose voters to confusing non‑human-readable ballots.

Members of the Technical Guidelines Development Committee discussed proposed 2.1 language that would restrict the use of barcodes and QR codes on ballots for tabulation except where those encodings are produced by voting paths intended for voters with disabilities.

"Barcodes are not accessible in themselves," Diane Golden said, urging that any exception for barcodes must require a clear definition of "accessible" and explicit identification of devices that generate them. "If you're going to limit barcodes to something that's accessible, then there has to be a clear definition of what's accessible and what isn't."

Several election administrators said barcodes already drive public confusion. Isaac Kramer described repeated precinct-level complaints and said his state’s use of barcodes for every ballot creates trust challenges among voters: "We get the calls, the angry voters in the precinct yelling about they can't understand how do I know this is counting what I intended it to count."

Cybersecurity and standards experts highlighted technical and transparency risks. Kevin Skoglin described research showing occasions where a barcode did not match human‑readable text on a ballot and warned that barcodes create a distinct attack surface and legal ambiguity about which representation counts as the official vote.

Supporters of tight limits pointed out a recent executive order directing reduced reliance on barcodes, while manufacturers said many vendors are already developing OCR and non‑barcode methods to provide accessible verification and tabulation.

Staff said the VVSG 2.1 draft includes requirements aimed at transparency — open formats and documentation for any barcode mapping — and that the executive order allows barcodes only when tied to accessibility. But members warned that leaving the wording vague could permit jurisdictions to use barcodes for tabulation while claiming an accessibility rationale.

The TGDC requested staff redrafts to make the role of barcodes explicit in 2.1 (for accessibility verification only, not for tabulation), to define the threshold for "accessible" devices and to spell out transitional or grandfathering rules for equipment already in the field.

No formal policy change was adopted at the session; members asked staff to circulate revisions before the committee’s next meeting.